CLI Phase II Report - Foreword

The Consumer Labeling Initiative (CLI), a pilot program
of the U.S. Environmental Protection Agency, was initiated in March 1996.
The initiation of the project was announced in a Federal Register (FR)
notice dated March 22, 1996 (61 FR 12011). The goal of the CLI is to foster
pollution prevention, empower consumer choice, and improve consumer understanding
of safe use, environmental, and health information on household consumer
product labels. The CLI is a multi-phased pilot project focusing on indoor
insecticides, outdoor pesticides, and household hard surface cleaners
(i.e., floor and basin, tub and tile), some of which are registered antimicrobials/disinfectants.
The CLI has involved a wide range of participants representing many interests
related to consumer labeling issues, including federal and state government
agencies, private industry, public interest groups, and individual citizens.

CLI participants have worked voluntarily for more than three years, with
the goal of finding ways to help consumers:

use information on the labels to reasonably compare products intended
for similar uses;

purchase, use, store, and dispose of products safely and with minimal
effect on the environment; and

make informed choices among products based on their own needs and
values.

Phase I of the CLI involved performing qualitative consumer research
and summarizing existing research and programs concerning the effectiveness
and limitations of labeling as a policy tool to protect public health.
The Phase I Report (EPA-700-R-96-001, September 1996) published
the findings, recommendations, and action steps that resulted from Phase
I research. Recommendations made at the conclusion of Phase I included
the suggestion for a second phase.

Phase II of the CLI began in October 1996. Phase II of the CLI followed
directly from Phase I, with the intention of providing more support for
the Phase I research findings. Its activities were intended to include
the following:

perform in-depth quantitative research to establish a baseline of
consumer understanding, attitudes, behavior, and satisfaction about
product labels;

carry out qualitative research on potential standardized information,
particularly for ingredients, precautionary statements, and signal words;

develop a multi-faceted, broad-based education campaign to 1) help
consumers understand and use labels effectively, and 2) disseminate
information about future labeling changes;

find simpler, clearer ways to word label information about what to
do in an accident or emergency involving household products;

perform research about storage and disposal information, with the
goal of improving labels to address conflicting laws, ordinances, and
community practices for waste recycling and disposal; and

identify other information about ingredients that consumers want and
need on labels for pesticides and other products.

The Executive Summary, which appears
before Chapter 1, highlights the types of research performed in Phase
II and describes important findings, implications, and conclusions of
the research, as well as the EPA recommendations developed through the
project.

Chapter 1, Overview of Phase II of CLI, describes the overall
process, structure, activities, findings, and recommendations of Phase
II of the CLI.

During Phase II, CLI participants funded and directed quantitative and
qualitative research to assess consumers' comprehension, attitudes, behavior,
and satisfaction with labeling; to evaluate alternatives; and to recommend
comprehensive, specific improvements to labels, as well as regulatory
or policy changes that would enable these improvements. Chapters 2, 3,
and 4 discuss in detail the quantitative and qualitative research process,
findings, and conclusions.

The quantitative segment of this research (Chapter 2) involved a detailed
and comprehensive national telephone and mail survey. Chapter 2 describes
the goals, methodology, process, and results of this quantitative research.
The results are discussed in two categories: findings and implications.
Findings result directly from the quantitative survey results and are
supported by the data. Implications, however, are derived from the findings
and are included to identify connections between separate but related
findings.

The qualitative research done in Phase I formed the basis of the quantitative
research, which in turn provided a necessary foundation for continuing
qualitative research in Phase II. The CLI's quantitative research team
identified a number of areas in which a more in-depth interview technique
could be used to advantage, particularly exploring consumers' preferences
regarding possible language and format options for standardized product
labels. Qualitative focus groups were designed and run with 27 groups
of consumers in different parts of the United States. This research is
described in Chapter 3.

The findings and implications reported in Chapters 2 and 3 are very extensive
and closely connected conceptually. To help readers assimilate these research
data and understand the directions in which they point, a separate chapter
(Chapter 4) outlines the conclusions of both the quantitative and qualitative
research. Conclusions, as used in this report, are defined as broad statements
-- arising from the research findings and implications -- about product
labels and consumers' comprehension, satisfaction, and preferences.

The next four chapters focus on other related work done during Phase
II. Chapter 5 discusses qualitative research that was performed to update
and improve First Aid statements on consumer product labels for indoor
insecticides, outdoor pesticides, and household hard surface cleaners.
The research involved in-depth one-on-one interviews with consumers to
identify problematic language and potential alternative wording.

The CLI is a collaboration among many different stakeholders, who explored
many issues related to product labeling for household insecticides, pesticides,
and hard surface cleaners. Chapter 6 describes the different subgroups
that contributed to Phase II, the specific activities undertaken by the
subgroups, the process followed by each subgroup, and the findings that
the subgroups generated. Specifically, this chapter describes the work
of (a) the Standardized Environmental Information Subgroup, (b) the Storage
and Disposal Subgroup, and (c) the Consumer Education Subgroup.

One of the most important elements of the CLI has been the coming together
of some of its most committed participants and stakeholders, including
CLI Partners and the CLI Task Force. The Task Force consists of federal,
state, and other regulatory entities with expertise and interest on labeling
issues. The Partners are a larger group of voluntary participants who
have expressed interest in these labeling issues and have made a long-term
commitment to participate actively in the work of the CLI. Several large
Partner and Task Force meetings were held during the course of Phase II.
Chapter 7 discusses the information that was presented at each of these
meetings.

Throughout its history, the CLI has encouraged the input and participation
of all interested individuals and groups, regardless of their level of
involvement. Stakeholders provided particularly valuable input in identifying
possible deficiencies in current labels and in suggesting options for
changes to EPA programs not directly related to product labels. Stakeholders
have included consumer product manufacturers, retailers, marketers, trade
associations, environmental labeling program practitioners, government
(federal, state, and local) agencies (including non-U.S. government agencies),
academics, public interest groups, consumer groups, environmental groups,
health and safety professionals, standards-setting organizations, media
groups, and individual citizens. Chapter 8 describes both the outreach
efforts made by the CLI to obtain comments from all interested stakeholders,
and the Stakeholder responses submitted in the course of Phase II. Chapter
8 focuses specifically on the participation of stakeholders other than
Partners and Task Force members.

Finally, Chapter 9 lists the recommendations for action that came out
of Phase II. The Partners and Task Force members together drafted and
approved recommendations regarding Signal Words and Hazard Hierarchy,
Ingredients, Label Formats, Consumer Education, and Storage and Disposal.
The CLI carefully considered all the Phase II research findings, implications,
and conclusions discussed in Chapters 2 through 4, as well as the supplementary
research described in Chapters 5 through 8, in coming up with its recommendations.
The final list of recommendations was submitted to EPA senior management
for consideration, and during the April 7-8th, 1999 Partner and Task Force
meeting, EPA announced which recommendations could be implemented immediately,
and which still needed approval from EPA senior management. (See Chapter
9 for details.)

Individuals who are interested primarily
in the outcomes of Phase II research should begin by reading the Executive
Summary, which outlines the goals of Phase II, briefly discusses the process
that was followed, and lists all the recommendations.

Readers with a strong interest in a particular topic may go directly
to one or more specific chapters. This report has been structured so that
each chapter can be understood independently of the others.

For readers who are interested in the Phase II research methodology and
findings, many of the Appendices to this report provide a great deal of
useful related information about the CLI and the Phase II research. A
complete list of appendices can be found in the Table of Contents. The
report and the appendices will be available in print from the National
Technical Information Service (NTIS) or from the Administrative Record
(AR-139). The report and the appendices will also be available electronically
through the Internet at the following site -- http://www.epa.gov/opptintr/labeling.

For further information about the Consumer Labeling Initiative, including
access to all previously published documents and descriptions of future
activities, readers are encouraged to visit the CLI website (http://www.epa.gov/opptintr/labeling).
Alternatively, interested parties can obtain CLI information from the
Administrative Record AR-139, located at the TSCA Non-confidential Information
Center, N.E. Mall Room B-607, EPA Headquarters, 401 M. Street, Washington
DC 20460. All raw data from the CLI research, correspondence, comments,
and publications are in the Administrative Record. Consumer Labeling Initiative
publications may be ordered from the Pollution Prevention Information
Clearinghouse by calling 202-260-1023 or by sending an e-mail to ppic@epa.gov.